U.S. v. Johnson

Dist. Ct. did not err when finding during sentencing proceeding that defendant was accountable for 23 grams of crack cocaine based on series of telephone calls that constituted evidence of drug transactions through use of code words. However, Dist. Ct. erred by not expressly responding to defendant's repeated requests for reduced, one-to-one crack-to-powder ratio when calculating amount of drugs at issue in instant drug conspiracy charge. Ct. of Appeals, though, rejected defendant's request to bar Dist. Ct. from using 100-to-1 ratio in remanded sentencing hearing.